ML20148J381
| ML20148J381 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 03/22/1988 |
| From: | Murley T Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20148J347 | List: |
| References | |
| 2.206, NUDOCS 8803300261 | |
| Download: ML20148J381 (10) | |
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, k .g UNITED STATES OF AMERICA NUCLEAR REGULATORY COMAISSION OFFICE OF NUCLEAR REACTOR REGULATION Thomas E. Murley, Director In tne Matter of SACRANENTO MUNICIPAL UTILITY DISTRICT, ) Docket No. 50-312 at al.
(Rancho !+ o Nuclear Generating Station) ) (10 CFR 2.206)
) l DIRECTOR'S DECISION UNDER 10 CFR 2.206 l
INTRODUCTION On August 26, 1986, the Honorable Tom Bradley, Mayor of Los Angeles, submitted '
l a Petition requesting t'1at the Nuclear Regulatory Commission (NRC or Commission) l corduct public hearings and permanently close the Rancho Seco Nuclear Generating station (Rancho Seco). In a letter dated September 26, 1986, the NRC Director of l
Inspection and Enforcement, James M. Taylor, responded to Mayor Bradley and informed h'm that his Petition would be treated under 10 CFR 2.206 of the'Comission's regu- ,
la t. ions. By letter dated December 15, 1986, Mr. Taylor provided additional informa- !
tion to Mayor Bradley on the status of his Petition. Mr. Taylor als" stated that a full response to the Petition would be made atter the NRC staff completed its evaluatinn of corrective actions taken by the plant's operator, the Sacramento 1
Municipal Utility District (SMUD), to improve the performance of Rancho Seco.
Mr. Taylor's letter further advised that the NRC evaluation of the corrective actions would be completed before the Commission made any decision on restart.
Mayor Br. 's reevest for a hearing and subsequent permane,nt closure of the Rancho Sec.- % ar Ge! >c. % Station is based on allegations thai.:
(1) Ranelc t .- ' !he Three Mile Island reactor; (2) the plant has had a troublei c - -
-n g3) the plant has suffered nearly one hundred unplannned outanas inclu.:Ing av n overcooling incident in industry history in 1978 and 8803300261 08037'2 POR ADOCK 05000312 P PDR,
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2 two severe overcooling incidents in 1985; and (4) the plant is plagued by poor l management, inadequate training, and sloppy maintenance.
In accordance with the following discussion, I find that the permanent shutdown of Rancho Seco is not justified. I have decided, therefore, to deny your request. I do note, however, that the NRC has not permitted SMUD to operate Rancho Seco for more than two years following an overcoolitig tranaisnt that occurred in December 1985. Curing thct time, a certprehensive evaluation to identify deficiencies at Rancho Seco was completed and a corrective action plan to correct the identified deficiencies was initiated. Thes6 actions resulted in significant inprovements in plant tranagement, maintenance, training, and in the overall mechanical condition of Rancho Seco.
_ BACKGROUND On December 26, 1985, Rancho Seco experienced a loss of de power within the integrated control system (ICS) while the plant was operating at 76% power.
Following the loss of ICS de pcwer, the ree.ctor tripped on high reactor coolant system (RCS) pressure. The reactor trip was followed by an overcooling transient that actuated safety features and resulted in excessive RCS cooldown. The over-cooling transient continued until ICS de power was restored 26 minutes later.
With restoration of ICS de power, the excessive RCS cooldown was stopped and the plant was stabilized.
Tha effects of the December 1985 transient were not, in themselves, signifi-cant in terms of decreasing the capacity of the plant to operate safely. However, the transient was the last in a series of undesirable events that raised the NRC's ;
level of concern over the ability of SMUD to operate a nuclear power plant safely. ]
The difficulties experienced by the Ranc'io Seco operators in recovering from the !
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transient focused attention on the poor material condition of the plant and SMUD's failures to initiate plant improvements that had previously been required by the NRC.
In cortpliance with a Con'irmatcry Action Letter issued by the NRC Region V Administrator, the Rancho Seco Nuclear Generating Station has remained shut down since December 26, 1985. Because of the concerns that the December 1985 events reised, the Confinnatory Action Letter confirrred that, before returning Rancho Seco to power operations, SMUD would (1) provide a root cause evaluatien of the reactor trip and overcooling event and (2) justify Rancho Seco's readiness to resurre power operations. SMUD has been responding to the Confirmatory Action Letter in stages, with step-by-step review and conynent by the NRC staff.
An Incident Investigation Team (IIT) was dispatched to the site to investigate the December 1985 transient ano related issues. The NRC staff has completed its investigation of the December 26, 1985 reactor trip and overcooline event and has published the results in NUREG-1195. This publication includes a description of the event and its significance, and discusses the precursors that led to the reactor trip and overcooling. The NRC staff evaluation of the ongoing restart effort has been published in NUREG-1286 and Supplement 1 to NUREG-1286 (Supp. 1).
NUREG-1286 and Supplea.ent I cororehensively evaluate SMUD actions to improve i overall perforrrance at Rancho Seco and to correct the deficierciet identified in NUREG-1195.
In response to the IIT report, SMUD developed the "Action Plan for Perfonnance Improvement", which addressed the problems identified in the IIT report and outlined a broad spectrum of issues to be addressed to improve the overall operational perfomance at Pancho Seco. The NRC staff rejected the initial versien of the SMUD Action Plan because it failed to address all the problems that needed attention. Additionally, the NRC staff independently initiated a review of the Rancho Seco performance history to identify areas of marginal
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i performance. This effort included a review of weaknesses identifiec during a series of post-shutdown inspections and evaluations. The staff indicated it would not accept the SMUD Action Plan until all problem areas identified by the staff were included in the performance improvement program.
Failure to make progress on these issues led to essentially a 100 percent turnover of plant ranagement and a complete nznagement reorganization at Rancho Seco. As part of the Action Plan, the new SMUD management eventually compiled a comprehensive list of the problems which included staff-identified deficiencies. ,
1 The SMUD Action Plan also included diagnostic programs to evaluate all areas of plant operatiens that are essential to successful overall plant performance.
The Action Plan required SMUD to incorporate any additional problems identified by diagnostic programs into the list of previously identified deficiencies. The j 1
NRC staff reviewed the completeness of the cumulative problem list. A corrective action program was established by SMUD to resolve all problems irjcluded on the cumulative prcblem list.
SMUD is acw resolving the identified problems. The status of SMUD's cor-1 rective action program, a description of the problems, and a description of the l
problem identification process are included in the NRC staff restart evaluation, hUREG-1286 and Supp. 1. The Comission will address the restart of Rancho Seco following the completion of (1) the SMUD perfonnance improvement program and (2) the NRC staff evaluation of the readiness of Rancho Seco to operate.
DISCUSS 10'<
The specific issues enumerated in Mayor Bradley's petition regard Mq plant design, alleged troubled operating record, unplanned outages, overcoolings, and alleged inadequate management, training and maintenance are thoroughly addressed by KUREG-1286. Pesolution of these issues in a manner satisfe.'iory to the NRC
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, 1 , staff was necessary before the staff would make a positive restart recommendation to the Ccmission. Completion of the proposed corrective actions ir plant hardware, Technical Specifications, procedures, management, and organization will result in significant performance improvement at Rancho Seco, which should preclude the types of concerns referenced by the Petition, including unplanned outages, overcooling, poor management, inadequate training, sloppy maintenarce, operating mistakes, equipment failures, and procedural and inspection violations.
The NRC staff evaluatio.1 of the effectiveness of these improvements which supports restart is documented in NUREG-1286.
Design Similarity To The TMI Reactor The Petition expressed concern that the Rancho St.co reactor is a twin of the Three Mile Island (TMI) reactor.
Even though the 1979 TPI accident was the most serious in the United States comercial nuclear power program, the plant's protective features successfully isolated the effects of the accident from the environment, and offsite radio- j logical consequences were minimal (Population Dose And Health Impact Of The Accident At The Three Mile Islano Nuclear Station, NUREG-0558). Nonetheless, j as a result of the accident a major safety reassessment of the comercial power program in the United States was initiated (e.g., TMI-2 Lessons Learned Task l Force: Status Report and Short-Term Recommendations, NUREG-0578; Clarificaticn of TM1 Action Plan Requirements, NUREG-0737). This reassessment led to a wide range of required modifications throughout the nuclear industry, targeted at reducing the likelihood of a THI-type accident (NUREG-0737, supra). The modi-fications included features that would improve the performance of the plant as well as the ability of the plant staff, the local comunity, and the nation to
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- respond to nuclear accidents (NUREG-0737, supra). The "lessons learned" from the TMI accident were incorporated into the nation's nuclear power program and into Rancho Seco as appropriate. Thus, the TMI accident served as a stimulus to enhance the safety of existing nuclear power stations.
The specific plant hardware improvements that were developed following the review of the accident-related events at TMI were most .mp'icable to reactors built by the Babcock and Wilcox Company (B&W), the manufacturers of the TMI reactor. As implied in the Petition, the Rancho Seco reactor was manufactured !
by B&W and benefitted substantially from the TMI accident experience. Rancho Seco also benefitted from the operating experiences of other B&W reactors.
Following an incident that involved the loss of auxiliery feedwater at a B&W i plant (Davis Besse) on June 9, 1985, and the overcooling incident at Rancho Seco on December 26, 1985, the NRC requested that the B&W Owners Group reevaluate l
the design of the B&W reactor systems to look for inherent weaknesses that could ;
1 make the reactors more susceptible to transients and accidents. The Owners !
l Group evaluations are documented in a report entitled ' Tety and Performance Improvement Program" (BAW-1919). The NRC staff assessmant uf this program is available as a Safety Evaluation Report, NUREG-1231. As explained in NUREG-1231, the Owners Group did not identify any major design flaws; however, it made more l
than 200 recomendations for improving operations at B&W plants and recontrendations applicable to Rancho Seco have been incorporated by SPUD. The NRC staff evaluation of BAW-1919, moreover, found no safety concerns that would preclude continued safe comercial operation of these facilities.
There are a total of eight B&W power reactors licensed to operate in the United States. Except for Rancho Seco, all the licensed B&W reactors, including TMI Unit 1, are operating. The operating records, of these reacters are not
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significantly different from those of other types of reactors in the United States. l l
As concluded in NUREG-1231, the B&W designed reactors can operate without undue 1
risk to the public health and safety. Accordingly, Rancho acco's design similarity l to THI-2 provides no basis to close Rancho Seco permanently.
Management The Petition describes the Rancho Seco operating history as "trcubled" and characterized by a series of unplanned outages ard reactor overcoolings. These occurrences have been r aluated by both SMUD and the NRC staff. The root causes of the problems invariably include management and the onsite plant staff.
A key issue in the Rancho Seco performance improvement program has been management competence. Since December 1985, the senior plant management has undergone a 100 percent turnover and more than 20 new managers have joined the SMUD staff. SMUD conducted a nationwide search for managers and was able to recruit experienced nuclear plant managers to direct future operations.
The NRC staff reviewed the resumes of these new managers and interviewed them. On this basis, and subsequent observations of plant recovery operations, the NRC staff concluded (NUREG-1286, Section 3.8) that the Rancho Seco management team appears well-qualified to prepare the plant to resume comercial operation, train the operating staff, and successfully operate the Rancho Seco Nuclear Power Station, i
Maintenance and Training The Petition included concerns related to inadequate training and sloppy l maintenance. The management changes instituted at Rancho Seco included changes in management of the maintenance and training departnents.
In both these areas, the new Rancho Seco managers have initiated programs l to correct identified deficiencies. The NRC staff considers improveinents in i
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these areas vital to successful plant operations and, as a result, has very closely evaluated the effectiveness of these improvement programs. The staff's conclusions are based on detailed program reviews conducted on site (NUREG-1286, ana Supp. 1, Section 3.4.1). In the case of training, the staff evaluation included observation of operators' performance at the B&W simulator in Lynchburg, Virginia (NUREG-1286, Section 3.4.1.2). The staff will cortinue close monitoring of these programs following plant restart. On the basis of its evaluation (NUREG-1286, Sections 3.3 and 3.4), the staff has concluded that Rancho Seco has develcred effective maintenance and training programs that should be capable of supporting successful plant operations.
Equipment Reliability In addition to management issues, the performance improvement program compre-hensively addresses plant hardware problems. Known equipment deficiencies were integrated into the perfomance improvement program as items to b,e resolved before restart. SMUD added new systems to the plant to optimize future oper-ations and improve the plant response to abnomal conditions. One of the new systen.s, the emergency feedwater instrurrentation and control system, is a major 1 hardware addition that provides redundant, safety-grade control of auxiliary feedwater (NUREG-1286, Section 3.1.3). Had this system been in place on December 26, 1985, it probably would have prevented the overcooling transient from exceeding the Technical Specification limit of 100*F in one hour (NUREG-1195, l Section7.2.3). SMUD has also established a preventive maintenance progran to provide assurance that equipment will remain in good operating order (NUREG-1286, Section3.3.1.5). I
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_9 A comprehensive equipment testing program is a major part of the performance improvement plan (NUREG-1286, Section 3.7). SPUD is testing individual components, systems, and integrated systems to ensure that original plant equipment and the newly installed systems operate as designed. The system test program extends through the projected plant restart. SMUD has proposed that following restart (criticality), it would continue testing systems under hot, low-power conditions during a six-month power ascension program (Supp. 1, Section 3.4.1.7).
The extended power ascension program will give the utility the opportunity to thoroughly evaluate operators during various startup conditions and will give the NRC staff an additional opportunity to monitor system performance and SMUD operating competence. This program should decrease the likelihood of future operaticnal mistakes and unplanned outages.
Overcooling Events and Unplanned Shutdowns:
The Performance Improvement Program was designed to decrease the likelihood of !
overcooling events and tc decrease the frequency of unplanned shutdowns.
Specifically, SMUD: (1) installed a safety-grade emergency feedwater initiation )
and control system (Supp. 1, Section 3.1.3); (2) added diesel generators to the onsite emergency grid (NUREG-1286, Section 4.7); (3) refurbished the ICS/NNI (NUREG-1286, Section 3.1); and (4) refurbished plant valves (NUREG-1286, Section3.3.2). These improvements in Rancho Seco's hardware systems .chould improve the plant's opera ing reliability and thereby decrease the number of unplanned shutdowns. Furthermore, improved operator training, maintenance l
procedures, and plant .nanagement, as described above, should reduce the number of human errors that cause unplanned shutdowns. In short, significant improve-ments have taken place at Rancho Seco since the 1985 shutdown. The improvements l should preclude the type of problems referenced in the petition.
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10 CONCLUSION The Petition requested the NRC to hold public hearings and shut down Rancho Seco pertranently. The institution of proceecings pursuant to 10 CFR 2.202 is appropriate only where substantial health and safety issues have been raised.
See Consolidated Edison Conpany of New York (Indian Point, Units 1, 2, and 3),
CLI-75-8, 2 NRC 173, 175 (1975), and Washington Public Power System (WPPS Nuclear Project No. 2), 00-84-7, 19 NRC 899, 923 (1984). This is the standard that I have applied to the concerns raised by the Petitioner in this decision to determine whether enforcement action is warranted.
For the reasons discussed above, I conclude that no substantial health and safety issues have been raised by the Petitioner which warrent the initiation of a proceeding to consider the permanent shutdown of Rancho Seco. Accordingly, the Petitioner's recuest for action pursuant to 10 CFR 2.206 is denied. As provided in 10 CFR 2.206(c), a copy of this Decision will be filed with the Secretary of the Coninission for its review.
FOR THE NUCLEAR REGULATORY COMMISSION l 1
Thomas E. Murley, Director {
Office of Nuclear Reactor Regulation Dated at Rockville, Maryland this 22nd day of March 1988 l l
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i D0-00-5 NUCLEAR REGULATORY COMMISSION SACRAMENTO MUNICIPAL UTILITY DISTRICT RANCHO SEC0 NUCLEAR GENERATING STATION Docket No. 50-312 ISSUANCE OF DIRECTOR'S DECISION UNDER 10 CFR 2.206 Notice is hereby given that the Director, Office of Nuclear Reactor Regulation, has issued a Director's Decision concerning a Petition dated fi; gust 26, 1986, filed by the Honorable Tom Bradley, Mayor of Los Angeles, California.
The Petitioner asked the NRC to hold pubite hearings and to shut down Rancho Seco permanently. The bases given by Mayor Bradley for the petition were allegations that: (1) Rancho Seco is a twin of the Three Mile Island Reactor, (2) Rancho Seco has had a troubled operating record, (3) Rancho Seco has suffered r.early 100 unplanned outages iiicluding two severe overcooling incidents in 1985, and (4) Rancho Seco is plagued by poor management, inadequate training, and sloppy maintenance.
On September 26, 1986, the Director, Office of Inspection and Enforcement, acknowledged receipt of the Petition. He informed Mayor Bradley that the Petiticn would be treated under 10 CFR 2.206 of the Coninission's regulations and that appropriate action would be taken in a reasonable time. In a letter dated December 15, 1986 Mr. Taylor infomed Mayor Bradley that a response to I his petition would be made prior to a restart decision but after the Staff l
evaluated corrective actions undertaken by the licensee.
The Director of the Office of Nuclear Reactor Regulation has new detemined that the Petitioner's request should be denied for the reasons set forth in the "Director's Decision Pursuant to 10 CFR 2.206" (DD-88-5), which is available for
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2 inspection and copying in the Commission's Public Document Room, 1717 H Street NW, Washington D.C. 2055K and at the Local Public Document Room for the Rancho Seco Nuclear Generating Station located at the Sacramento City-County Library, 828 I Street, Sacramento, California 95814.
A ccpy of the Decision will be filed with the Secretary of the Commission for its review in accordance with 10 CFR 2.2C6(c). Asprovidedin10CFR?.206(c),
the Cecision will become the final action of the Commission twenty-five (25) days after issuance unless the Commission on its own motion institutes review of the Decision within that time. .
FOR Tite NUCLEAR REGULATORY COMMISSION I
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Thomas E. Murley, Director Office of Nuclear Reactor Regu Dated at Rockville, Maryland, this 22nd day of MarcF 1988 i 1
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August 26, 1986
'95 SEP -3. P 4 :)4 l
Honorable Nunzio J. Palladino .'
Chairman CFTCE ~ ..
Nuclear Regulatory Commission 00CKiipp 3' '!1' 1717 "H" St., N.W.
Washington, D.C. 20555 WCr.2T MUMtER -
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Puoo.& tm L F** b.M"%
SUBJECT:
Request for Public Hearings on Closure of Rancho Seco
Dear Chairman Palladino:
The Rancho Seco Nuclear Power Plant, located near Sacramento, California, is America's most dangerous nuclear power
, facility. I call upon the Nuclear Regulatory Commission to conduct public hearings and then to shut down Rancho Seco permanently.
The simple fact that Rancho Seco is a twin of the docmed Thre,e Mile Island reactor is enough reason to closely scrutinize the plant's operation. But Rancho Seco's j0 I
troubled operating record offers many more reasons for concern.
In just eleven years of operation, Rancho Seco has suffered nearly 100 unplanned outages -- including the worst overcooling in industry history in 1978 and two severe overcoolings just last year. In fact, Rancho seco has already suffered as many "incidents" as most nuclear power plants endure in twenty years.
Furthermore, both NRC records and independent investigations reveal that Rancho Seco has been plagued by poor management, inadequate training, and sloppy maintenance. Indeed, in nearly every year of operation, Rancho Seco has experienced an increase in the number of operating mistakes, equipment failures and procedural and inspection violations. (In the only two years i in which Rancho Seco did not experience increases in violations, the plant was closed for about two-thirds of the time.)
Fortunately, Rancho Seco has been completely shut down since it suffered the third worst overcooling accident in industry history in December, 1985. As you know, the NRC is now deciding when, and under what circumstances, Rancho Seco may begin operations again.
I believe that an unbiased review of the evidence supports the conclusion that Rancho Seco should never be reopened. But
'/ whatever the evidence, I urge the NRC to give interested
- ( members of the public an opportunity to testify, at open i hearings, concerning the future of Rancho Seco. The residents of
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/l the Sacramento area, who would be catastrophically
- impact'ed by an accident at Rancho Seco, have a right to be heard,
- and heard powerfully, on this critical issue.
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Furthermore, the public has a right to know about the
['s horrendous mismanagement at Rancho Seco -- mismanagement that -
continues at this very moment. For example, the NRC national office's most recent evaluation of the start-up plan prepared by Rancho Seco's management (a copy of which is attached hereto) reveals yet additional management errors. Incredibly, the NRC report concludes that the Rancho Seco start-up plan -- after .
months and months of preparation -- fails even to address the major problems that led to the near-catastrophe in December, 1985. See NRC Report, subpoint 1, page 1. In addition, the NRC report highlights three other significant deficiencies in the Rancho Seco start-up plan. In short, .after eight months of work, Rancho Seco's management cannot even begin to assure the public that the plant will be operated safely if it is reopened.
In light of Ranche Seco's incredibly dangerous operating history, and in view of the continuing inability of the plant's managers to behave competently, I urge the NRC to conduct public hearings and then to permanently close Rancho Seco.
Sincerely, ,
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TOM BRADLEY Enclosure
- . UNITED sT ATEs /
( NUCL E AR REGUL ATORY COMMISSION 3g#[
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[ W A5mNGioN. O. C. 20555 July 8, 1986
[s e ,' v.....f RECElVED
/ LICENSEE - Sacramento Municipal Utility District K 2 4 19 %
FACILITY - Rancho Seco Nuclear Generating Station RANCHOSECO SUBJECT -
SUMMARY
OF MEETING HELD ON JUNE 12, 1986 WITH SACRAMENTO MUI'CIPAL UTILITY DISTRICT By letter dated May 30, 1986, the Sacramento Municipal Utility District (SMUD) submitted a preliminary version of its Action Plan for Perfnrmance Improvement at the Rancho Seco Nuclear Generating Station, in its letter SMUD stated that tha preliminary plan was not intended to be used for detailed review but was intended to be a communicatinns vehicle to serve as the basis for discussions between the NRC staff and SMUD. On June 12, 1986, a meeting was held between representatives of SMUD and the NRC staff in Bethesda, Maryland to discuss the scope and content of the action plan. Enclosure 1 is a list of the attendees.
Enclosure 2 is a copy of the material presented by SMUD at the meeting.
SMUD provided a brief overview of the organizational changes and management personnel additions made to improve management performance. They also described the nature of the Plant Performance (PP) and Management Improvemer.t Program (MIP) process. As shown on Enclosure 3, the PP and MlP process involves the steps of "input," "evaluation," "disposition", and "implementation." Recomendations for consideration in the PP and MIP process will consist of input from six investigative groups. The six investigative groups sre (1) Selected Prnjects, (2) Precursor Reviews (3) Plant Staf f Interviews, (4).Deteministic Failure Consequences, (S) BWOG Stop-Trip Program, and (6) December 26 Event and Nureg-1195 Action List. The inputs will be evaluated and prioritized by the Recomendation Review and Resolution Board. Disposition of the recomendations will be made by the Perfomance Analysis Group and implementation will be accomplished by the existing organization and procedures. The licensee indicated that the review groups will continue working after restart. The criteria tl'e licensee is using for prioritizing restart actions are those that (1) assura the plant remains in ,
the post-trip window, (2) assure ccmpliance with license requirerents, and (3) preclude the need for "Heroic Operator Action."
SMUD then gave a brief description of the Preventative Maintenance Program that is currently underway. The program will include inspection of over 300 manual valves, inspection of selected motor operator valves, and reverifyWg~
settings on main steam valves. SMUD also described their proposed systens test program. The program consisted of primarily surveillance tests, test of systems and components on which nodifications were made or maintenance perfomed, and integrated systems startup tests. In addition SMUD is studying the Davis-Besse and TMI test prograns and some selected systems testing may be performed.
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The NRC staff had the following major coments:
- 1. The preliminary version of the Action Plan does not indicate that the
. retrospective matters raised by the Incident Investigation Team in Chapter 7
.-.a uu.q 7A ye y (g er y RECElVED ml -l 1
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/) of NUREG-1195 will be addressed.
these matters prior to res tart, The staff considers that SMUD must a f/'
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i completed prior to restart, and on what schedu
, discussion of why other items need not be resolved prior to restart For a number of items, the Action Plan indicates that resolution will be ii d
! initiated prior to restart, but no schedule is provided for completion .
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yl Although the Action Plan appears to include both a systems review and ,
j p ! test of program, these elements.it does not adequately describe the depth or interrelati
! The NRC staff believes that the test prog'.am should j j be developed and its scope justified based on the systems review and configuration evaluations, i !
i j Based on the limited detail provided in the preliminary version of-the
! Action Plan and the schedules indicated, the NP.C stiff is corcerned that
/. { the test program appears to include little more than the normally 3
expected post-outage startup testing.
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,.I The Action Plan makes frequdnt references to utilizing information to be h :
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between, SMUD and the Owners Group, and confirma i$
1i schedules are consistent with SMUD's plans for restart.
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{j Sydney Miner, Project Manager
'l ,! Project Directorate #6
$; Division of PWR Licensing-8 Al Encisoures:
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As Stated i
cc w/ enclosures:
- See next page .
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